Dual-use export controls: China requires licences for tunnel boring machines and drone parts from 18 November

MONDAY, 19 OCTOBER 2026

Four notices from Beijing widen the dual-use list and set the timeline for customs holds: 7 working days for documents, then up to 15 plus 15 for a decision.

Dual-use export controls in China: from 18 November 2026 Beijing will require licences or registration for exports of tunnel boring machines, some drones and their components. On 19 October the Ministry of Commerce and the customs administration published four notices, numbers 49 to 52, that update China's list of dual-use items.

Dual-use export controls: what enters China's list

Notice 50 introduces controls on three families of construction machinery. The first is full-face tunnel boring machines, both earth pressure balance and slurry shields and hard-rock machines, together with the components designed for them: cutterheads, screw conveyors, segment erectors and main drive systems, plus the technology to remanufacture them. The second is walking excavators with extreme-terrain performance; the third is wet shotcrete machines designed for sites above 3,000 metres of altitude.

Notice 49 updates controls on drones and their parts, notice 51 those on dredger pumps and tools. Notice 52, in force from the day of publication, rewrites the procedure by which Chinese customs stops a suspicious shipment.

Technical thresholds and timelines

The notices set precise parameters, and these decide whether goods are controlled or not:

• Drones flown beyond the operator's line of sight: controlled with an endurance of at least 3 hours, or from 30 minutes to 3 hours if they take off and fly stably in gusts of 46.3 km/h
• Other drones: controlled with a range of at least 300 km, or with autonomous flight and a spraying system above 80 litres
• Brushless motors for drone propellers: controlled from 48 V and 3 kW rated upwards, if they also meet the power density and speed thresholds
• Walking excavators: controlled if they climb vertical obstacles above 1.2 metres, ford water deeper than 1.5 metres, cross trenches wider than 3 metres or climb slopes steeper than 40 degrees
• Dredgers: pumps with a suction inlet of 0.55 metres, casings and impellers of 1.3 metres, dredging cutters of 2.1 metres in diameter and above

For tunnel boring machines the regime has two tiers. A licence is needed to sell to "sensitive countries and regions that have disputes with China", which the notice does not list; for all other markets it is enough to register the shipment and obtain an export certificate, with the exporter and the end user committing not to transfer the machine to those countries without authorisation.

What it means for importers from China

The part that affects the most companies is the declaration requirement. For controlled goods the supplier must write "dual-use item" in the customs declaration with the control code; for goods with parameters close to the thresholds it must write "not controlled" and state the technical values. If the data look incomplete or doubtful, customs can hold the goods.

Notice 52 sets the timeline of the hold. The exporter has 7 working days to hand over the contract, invoice, transport documents, a technical statement and any test reports, with a Chinese translation of foreign-language texts. Customs decides within 15 working days or refers the case to the ministry, which has another 15 working days. Throughout, the shipment stays put; goods unrelated to the challenge, if included in the same declaration, can be split off with customs' consent. The same rules apply to cross-border e-commerce, mail and express couriers.

The text does not say how often customs will use this power. It does suggest, however, that buyers of agricultural drones, high-power electric motors or spare parts for excavation machinery should allow for a possible hold of more than a month before loading in contested cases.

How to prepare by 18 November

The first step is to ask the supplier whether the ordered product falls under the new codes or has parameters close to the thresholds: endurance, motor voltage and power, component dimensions. The second is to obtain in advance the technical sheet that will go into the export declaration, so that the data match those in the Italian documents.

For orders delivered after 18 November it is also worth reviewing contracts: a clause that moves the delivery date in case of an export control hold protects both parties. The ministry states that compliant applications will be approved, but gives no timeline for issuing licences.

A widening effort

The notices come three days after the consultation opened on 16 October on new export restrictions for artificial intelligence, biomedicine and photovoltaic technologies. The direction is the same: more goods under control and more data required at customs.

With La Merce, those ordering drones, electric motors or construction spare parts in China after 18 November receive from the supplier, before loading, the technical parameters to declare, so the goods do not sit in customs for the 7 plus 15 plus 15 working days the procedure allows.

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